On 17 December 2014, the US Treasury Department blocked the property of 11 individuals and entities, spread across 4 countries, pursuant to E.O. 13582, which authorises sanctions against persons that provide material assistance to the Syrian regime.  Among the entities designated were the Abdulkarim Group, based in Syria, Maxima Middle East Trading Co., based in the United Arab Emirates (“UAE”), Staroil B.V., based in the Netherlands, and Rixo International Trading Ltd., Bluemarine SA and Skirron Holding, all based in Switzerland. The designated individuals were primarily the senior executives and owners of these entities.

According to the Treasury Department, these entities and individuals provided support to the Syrian regime and to Pangates International Corporation Ltd., which was previously designated under E.O. 13582, primarily by assisting in the delivery of specialty fuels and base oils to Syria for military use. The Treasury Department asserts that there is evidence that these entities used falsified shipping documents to mislabel and misrepresent the true contents and destination of the fuels and base oils.

In addition being placed on the Specially Designated Nationals (“SDN”) list under E.O. 13582, six of the entities and individuals were also added to the Foreign Sanctions Evaders (“FSE”) list under E.O. 13608, which authorises imposition of sanctions on persons who have facilitated deceptive transactions on behalf of the Government of Syria.